Subject: File No. 4-606
From: Dennis B Lerner, CLU Chfc
Affiliation: Registered Rep

August 16, 2010

I have been in the insurance and investment business over 41 years. I am all in favor of reasonable regulation as I feel it protects both my clients and my career. I am not sure the new proposed regulations will have a positive impact for the consumer. It is difficult to determine what is in the best interest of the client. Most companies use projections and it is not until you get 20 years down the road can really determine how well a product does. I feel regulation has to reasonable to be effective. Crooks will still be crooks.